As described in a previous blogpost, there are major ethical concerns arising from the use of covert psychological strategies within the Government’s coronavirus communication campaign. Inflating fear and shame in the general population, while encouraging peer pressure towards those deemed to be non-compliant with the restrictions, have been approaches recommended by the Government’s ‘Scientific Pandemic Insights Group on Behaviours’ (SPI-B), a group of experts comprised mainly of behavioural scientists and psychologists. On the 6th January 2021, I - along with 46 psychologists and therapists - wrote a letter to the British Psychological Society (BPS), the organisation responsible for overseeing the practice of psychology in the UK, to seek their perspective regarding the ethical basis of deploying covert ‘nudges’ to promote compliance with a contentious and unprecedented public health strategy.
On the 5th February, I received a response from the BPS, which is reproduced in full below:
Dr Gary Sidley
5th February 2021
Dear Dr Sidley
Thank you for your email and letter to the British Psychological Society.
Responses to the specific queries raised in the letter are provided below.
1. Does the BPS believe that the use of covert behavioural strategies, without explicit public consent, to ‘nudge’ people to comply with Government policies is a legitimate use of psychological skills and knowledge?
It is not possible to conclude from the information provided in your letter, and that which is publically available, that covert rather than overt behaviours strategies have been used to encourage people to comply with Government Policies.
BIT work in multidisciplinary teams that may include psychologists. The specific role of any BIT psychologists in such strategies is also not evidenced.
Our own guidance “Delivering effective public health campaigns” is based on an established, evidence-based behaviour change framework – COM-Bi (Michie, van Stralen, and West, 2011) which can be tailored to what people may need to optimise behaviour. Behaviours are key to preventing infection and improving outcomes.
2. Is it ethically acceptable to use covert psychological strategies to increase compliance with contentious public health policies, such as the Government’s coronavirus responses?
It is not possible to conclude from the information provided in your letter, and that which is publically available, that covert behavioural strategies have been used to increase compliance with public health policies. It is not appropriate for us to comment on whether the Government’s coronavirus response has used contentious public health policies. As mentioned in the previous response, we have published our own evidence-based guidance on effective public health campaigns and this includes recommendations for appropriate and effective messaging.
3. Does the BPS agree that BIT psychologists who recommended that the Government’s coronavirus campaign use covert strategies, that purposefully increase fear and encourage the scapegoating of the non-compliant minority, are practising in a way that infringes the BPS Code of Ethics?
We cannot comment on specific role of the Behavioural Insights Team (BIT) may have played in advising the Government on its Covid-19 strategy. It is also not appropriate for us to respond to concerns regarding the practice of a group of non-identified psychologists (who may or may not be members of the Society).
4. Assuming that the BPS recognises that there are some ethical issues arising from the use of covert psychological techniques in the ways described, what does the BPS propose to do to address these issues?
Our guidance in relation to optimising behaviour to support individual, community and population efforts to reduce the spread of coronavirus, based on psychological principles, is clearly set out in the published documentation referenced above in response to point 1.
Psychology is crucial to reducing the spread of Covid-19 as it enables us to understand and change behaviour and anticipate people’s responses to changes in policy and guidelines.
If you have specific concerns about named psychologists, these can be reviewed under our complaints procedure, Code of Ethics and Member Conduct rules. As the BPS is not a regulator, we do not have statutory enforcement powers beyond reprimanding, suspending or expelling a member from the society.
If the individual is a member of staff at a Higher Education Institute or is employed by the Government or a Research Organisation you will need to raise the complaint with their employer under their complaints procedure.
5. To minimise the likelihood of psychologists acting in an unethical way in the future, and to thereby prevent a repeat of the widespread ‘collateral damage’ associated with applying covert psychological strategies to win compliance with contentious public health policies, would the BPS publically condone the use of psychological skills and knowledge for this purpose?
As emphasised above, psychology has a crucial role to play in helping us to understand and change behaviour and anticipate people’s responses to changes in policy and guidelines regarding the virus. Behaviours are key to preventing infection and improving outcomes and we set out a series of recommendations to optimise policies and communication in our document Behavioural science and disease prevention: Psychological guidance
Pandemic transmission and effects are complex, as is its management. This includes a multifaceted approach, enabling behaviour by educating, training, persuading and using the environment to support behaviour change, and working to protect and mitigate harmful effects on people’s lives, including their physical and mental health.
We are incredibly proud of the fantastic work done by psychologists throughout the pandemic. The BPS COVID-19 Coordinating Group has produced a wealth of evidencebased resources for practitioners and the public. This included evidence-based guidance on optimising public messaging for a range of audiences. We will continue to be guided by the science in our response to the pandemic and its long-term impacts.
DEBRA MALPASS (Dr)
Director of Knowledge and Insight
i Michie, S., van Stralen, M.M., and West, R. (2011). The behaviour change wheel: A new method for characterising and designing behaviour change interventions. Implementation Science, 6, 42. https://doi.org/10.1186/1748-5908-6-42
My initial thoughts about the BPS response
It is disappointing that the BPS has not attempted to address the concerns raised in our initial letter. As the organisation responsible for overseeing the practice of psychology in the UK, it is reasonable to expect that the BPS would reflect on the ethics of strategically using fear, shame and peer pressure (all of which rely on emotional distress as a mediator of behaviour change) to achieve compliance with unprecedented and contentious coronavirus restrictions. From Dr Malpass’s response, it seems unlikely that our questions were considered by their ethics committee – I have subsequently contacted the BPS again to seek clarification on this, and have since been informed that the issues documented in our initial letter will be addressed at the next BPS ethics committee on the 1st March.
The BPS reply to our questions is evasive and disingenuous. First, to state that ‘it is not possible to conclude … that covert rather than overt behaviours strategies have been used’ is akin to denying that fear elevation, shaming and peer pressure (or a focus on ‘affect’, ‘ego’ and ‘norms’, to adopt the language of the behavioural scientists) have been deployed in the Government’s COVID-19 messaging campaign. I discussed examples of the widespread use of these strategies throughout the pandemic in a previous blog. Plus, we now have to endure the, ‘LOOK THEM IN THE EYES AND TELL THEM YOU’RE DOING ALL YOU CAN’ mantras; hardly a message that relies on information provision and overt reasoning to change the behaviour of our citizens.
Second, to suggest that a reason the BPS cannot comment is that I’ve not named specific psychologists is to miss the main point of our initial letter, which was to understand the BPS’s position on the use of covert psychological strategies to achieve the general public’s compliance with a public health policy. I believe that the behavioural scientists involved in advising the Government are very effective at what they do and are acting in good faith, and that they view their roles as altruistic. It is beyond doubt that some of those involved in the SPI-B are also members of the BPS – a cursory look on GOV.UK would confirm this – so it is not justified to highlight our omission of named practitioners as a reason for not responding to our ethical concerns.
Third, the leading proponents of behavioural ‘nudges’ to improve compliance with Government policies explicitly state that the consent of the public must be obtained before these strategies are implemented. Thus, in the 2010 document, MINDSPACE: Influencing behaviour through public policy (co-authored by Dr David Halpern, a member of both the SPI-B and the main SAGE committee) it is stated that, ‘policymakers wishing to use these tools … need the approval of the public to do so’ (p74). In a recent publication (Halpern, 2019), Dr Halpern is even more emphatic about the importance of gaining public consent before covert strategies are deployed: ‘If Governments … wish to use behavioural insights, they must seek and maintain the permission of the public. Ultimately, you – the public, the citizen – need to decide what the objectives, and limits, of nudging and empirical testing should be’. Clearly, the widespread use of covert psychological strategies in the Government’s coronavirus messaging campaign, without any apparent attempt to gain the public’s consent, raises significant ethical concerns that the British Psychological Society should address.
I welcome the news that the ethics committee of the BPS will, on the 1st March, consider the issues raised in our initial letter. I will await their response before deciding upon the next steps.
Halpern, D. (2019). Inside the Nudge Unit: How small changes can make a big difference. WH Allen, Penguin Random House UK.
Photo courtesy of @bannonmorrissyphotography